3 Instruments for implementing the NWMS

3.1 Introduction

This section describes the regulatory and economic instruments that will give effect to the strategy set out in Section Two. The Act provides a toolbox of waste management measures to deal with the challenges of particular waste streams. Regulations issued in terms of the Act will give effect to these measures.

The measures described in this section are:

Waste Classification and Management System – provides a methodology for the classification of waste and provides standards for the assessment and disposal of waste for landfill disposal

Norms and standards – baseline regulatory standards for managing waste at each stage of the waste management hierarchy.

Licensing – the Act provides for a list of waste activities that require licensing and the setting of licensing conditions. The Act also provides for listing waste management activities that do not require a licence if undertaken according to specified norms and standards or requirements.

Industry waste management plans – enables collective planning by industry to manage their products once they become waste and to collectively set targets for waste reduction, recycling and re-use.

Extended Producer Responsibility (EPR) – identifies particular products that have toxic constituents or that pose waste management challenges, and regulates industry responsibility for these products beyond point of sale.

Priority wastes – identifies categories of waste that require special waste management measures due to the risks of these wastes to human health and the environment.

3.2 Waste classification and management system

Chapter 2, Part 2 of the Waste Act requires that national norms and standards for the classification of waste should be developed. The waste classification and management regulations provide a waste classification system for all wastes managed under the Waste Act. Waste is to be classified according to the Globally Harmonised System of Classification and Labelling of Chemicals (GHS)40. GHS classifies hazardous substances according to the type and degree of risks that chemical compounds in different physical states (i.e. solid, liquid or gas) pose to human health and the environment.

Waste streams that are clearly identifiable will be pre-classified. Waste generators will not need to classify these wastes in terms of the WCMS. Examples of pre-classified wastes include domestic waste, uncontaminated building and demolition waste, business waste collected by municipalities, tyres, garden waste, post consumer packaging, asbestos wastes and health care risk waste.

The waste classification and management regulations set timeframes in which waste must be classified and managed, including wastes stored in lagoons. The regulations prohibit the mixing of waste prior to classification and require that co-disposal of domestic waste and industrial waste be phased out. Timeframes are also set for the phase out of macro encapsulation of waste.

Section 19(3)(a) of the Waste Act specifies that the Minister may, by notice in the gazette, indicate:

whether a waste management licence is required for listed waste management activities; and

the requirements or standards that will apply to listed activities for which licensing is not required.

To encourage re-use and recovery of industrial wastes the WCMS establishes a procedure for submitting motivations to the Minister for the listing of waste management activities that do not require a waste management licence. In the motivation to the Minister the applicant must provide details of local and international specifications or standards relating to the waste and the waste management activity41 as well as supply proposed requirements or standards specific to the waste management activity that would ensure that the activity can be implemented and conducted consistently and in a controlled manner42. The use of slag as aggregates for road building and the use of ash for cement extenders and brick making are good examples of wastes activities for which licences may not be required should certain requirements be fulfilled.

The WCMS regulations will replace the DWAF Minimum Requirements for the Handling, Classification and Disposal of Hazardous Waste. For hazardous waste, the WCMS institutes a management system consisting of waste manifests, safety data sheets, container labelling and detailed storage records:

All generators of classified hazardous wastes must complete a waste manifest document that accompanies the waste until a manager at the point of disposal issues a receipt for the waste on the manifest.

Apart from the waste manifest, the WCMS requires that a safety data sheet43 accompanies all hazardous wastes, including contaminated general waste.

Containers that store hazardous wastes must be labelled and storage facilities must keep detailed records.

This system will improve the management and quality of data available on hazardous wastes and ensure reporting to SAWIS.

The WMCS includes two new standards: the Standard for Assessment of Waste for Landfill Disposal and the Standard for Disposal of Waste to Landfill.

The first standard contains the requirements to assess the level of risk associated with the disposal of waste to landfill. The level of risk is based on identifying contaminants present in the waste and comparing these with determined limit values44. The second standard provides for landfill classification and containment barrier design requirements45, which supersede the liner design requirements for landfills contained in the Minimum Requirements for Waste Disposal by Landfill46. The standards also include waste disposal restrictions and timeframes in which the wastes may no longer be disposed to landfill. This will encourage the development of alternative options for the management of these waste streams.

As specified in SANS 10234

Regulation 9(g)

Regulation 9(l)

In accordance with SANS 11014

Both the total concentrations (TC) and the leachable concentrations (LC) for specified contaminates are to be determined. These concentrations must then be compared to the four levels of threshold specified. Risks are associated with each threshold. The standard prescribes the test methods for both the total concentration tests and the leachable concentration tests.

It provides for containment barrier designs, for class A, B, C and D wastes and identifies which type of waste can be disposed on which liner design. Furthermore, the disposal of very high risk waste to landfill is not allowed. The waste must be treated and re-assessed. High risk waste may be disposed of to a Class A landfill design. Moderate Risk waste to a Class B landfill design. Low Risk Class C landfill design. Inert Waste Class D landfill design.

2nd Edition, 1998; Department of Water Affairs and Forestry

3.3 Norms and standards

The Waste Act allows for an integrated system of norms and standards across the three spheres of government. The drafting of certain norms and standards at a national level are obligatory, while others are at the discretion of the Department of Environmental Affairs. In addition, provinces may set norms and standards that are not in conflict with national norms and standards. Municipalities may also set local waste service standards. The system of norms and standards will be developed in a sequenced manner, with the priority to develop obligatory standards, which include:

7(1)(a) classification of waste;

7(1)(b) planning for and provision of waste management services; and

7(1)(c) storage, treatment and disposal of waste, including the planning and operation of waste treatment and waste disposal facilities.

In relation to the classification of waste, the waste classification and management regulations discussed in Section 3.2 will be finalised in 2012.

In relation to waste services (Section 7(1)(b), the National Domestic Waste Collection Standard addresses the collection of waste and includes requirements for separating waste at source, measures to promote recycling, and prescriptions for collection frequency.

In terms of discretionary national norms and standards, the priority is to develop technical standards for waste management activities that do not require a licence. These standards will promote re-use, recycling and recovery of wastes. Standards will also be developed for soil quality and remediation of contaminated land. These standards will be finalised in 2012.

Other discretionary norms and standards will be identified and developed using the following criteria:

Contribution to achieving the waste management hierarchy, with particular focus on the re-use, recycling and recovery of wastes.

Extent of the environmental impact.

Impact on availability of landfill space.

Relationship to other priority sectors (such as waste-to-energy and its contribution to the climate change mitigation strategy).

Existence of standard operating procedures which may be converted into standards for particular sectors or companies with multiple sites.

Elements of the waste transportation sector that have not been properly regulated.

To prevent a proliferation of norms and standards, provisions for provincial and local government norms and standards will only be used where national provisions cannot effectively address provincial or local waste management issues. Instances where possible regional variation might be required will be identified and discussed in the appropriate intergovernmental forums.

3.3.1 Mechanisms for developing standards

There are two primary mechanisms to develop norms and standards. Standards that are non-technical, or on which there is already clear consensus, will follow DEA's internal procedures for standard setting as with the development of the National Domestic Waste Collection Standards. The development of complex technical standards that must be scientifically exact will use the standard setting procedure of the South African Technical Infrastructure (SATI), which falls under the South African Bureau of Standards (SABS).

SABS standards are developed via a consensual process using multi-stakeholder committees that involve those responsible for meeting the standards in the development of their content. In instances where consensus on the standards is not achieved within a realistic timeframe, DEA will exercise its prerogative to promulgate the standards based on its own technical assessment.

While standards developed through SABS are voluntary, the Waste Act empowers the Minister to make such standards mandatory. Once a standard has been developed through SATI, it will be promulgated in terms of regulations issued under the Waste Act. Where required, additional regulatory provisions will support the promulgated standards.

Agents accredited by the South African National Accreditation System (SANAS) will certify compliance with the developed SABS standards. The SABS will use globally standardised measurements, which the metrology unit of SABS provides on request. Whilst SANAS will not offer training to private agencies, it will provide accreditation training for their assessors.

DEA and the SABS will sign a memorandum of understanding that sets out the basis on which the Department can develop certain technical standards through the SATI mechanisms.

3.4 Licensing Waste Management Activities

The purpose of licensing is to ensure that specific conditions regulate identified waste management activities (as currently listed47) that may have a detrimental effect on the environment. Chapter five of the Waste Act provides for licensing waste management activities. Licence conditions are monitored and enforced to ensure environmental protection.

Department of Environmental Affairs (2009) National Environmental Management: Waste Act, 2008 (Act 59 of 2008) List of waste management activities that have, or are likely to have a detrimental effect on the environment. Government Notice No.718, 3rd July 2009.

3.4.1 Listing of waste management activities

The requirement for licensing applies to a range of listed waste management activities including the storage of waste; recycling, recovery; treatment of waste; disposal of waste; and the construction or decommissioning of facilities and associated structure and infrastructure. The list has Category A and B and what differentiates the activities in A & B is the threshold.

The Waste Act requires that the notice listing the waste management activities must indicate whether a waste management licence is required for that activity or, if not, the standards or requirements that govern the activity. Where a standard or requirement has been set, listed waste management activities that are exempt from licensing requirements must comply to that standard. In addition, they must register with and report regularly to the SAWIS.

Applications can be made to the Minister through the process identified in the Waste Classification and Management regulations for activities to be exempted from requiring a licence on the grounds of its contribution to waste minimisation or diversion of waste from landfill.

3.4.2 Licensing process

The Waste Act provides for a licensing regime specific to waste management activities. It replaces the historical system of permits issued in terms of the repealed section 20 of the Environment Conservation Act, 1989 (ECA). Transitional arrangements allow existing permits granted in terms of ECA to be regarded as licences in terms of the Waste Act until the Minister requires a licence application as per the Waste Act.

The category of the waste management activity (A or B as explained in the previous section) determines the environmental assessment procedure (which is the equivalent of the EIA regulations' requirements) required to obtain a licence.

Category A activities need a basic assessment as defined in the environmental impact assessment (EIA) regulations provided in NEMA. A basic assessment is appropriate where the environmental impact of a particular activity is well understood and limited in scope. Category B activities require a full assessment report in terms of the EIA regulations. A full assessment is appropriate where the potential scope and extent of environmental impacts is not well understood, or is likely to be significant.

The waste management licence applications will be captured in the National Environmental Authorisation System (NEAS).

An independent Environmental Assessment Practitioner (EAP) will manage all licence applications. The independence of the practitioner will be established through a formal disclosure of interests by that person in the waste management licence application form. The Minister is the licensing authority with respect to hazardous waste, international obligations, activities performed by a provincial environmental authority or statutory body other than a municipality, or an activity that takes place in more than one authority or that traverses international boundaries. National EMIs will monitor compliance with licences for which the Minister is the licensing authority.

The MEC is the licensing authority for waste activities for which the Minister is not the licensing authority. The Minister is also empowered to delegate licensing authority for a particular waste management activity to the MEC and the MEC can request the Minister to be a licensing authority for activities which the MEC is the licensing authority. Provincial EMIs will monitor compliance with licences for which the MEC is the licensing authority.

DEA integrated environmental information systems will provide the capacity to address the significant number of new licence applications. The framework will use a workflow engine that will automatically route licensing applications and the relevant documentation along the chain of approvals and authorisations. Furthermore, the applicant will be able to track their application online and reporting tools will assist DEA to identify and resolve bottlenecks in the system.

DEA's overall intention is to simplify and expedite the licensing process as well as promote the streamlining and integration of multiple licensing processes. DEA has implemented an integrated permitting system for activities that require both a waste licence as well as an environmental authorisation per the EIA regulations. Furthermore, a standard operating procedure for integrated permitting has been established to facilitate integrated permitting at provincial level.

In the long term, DEA's goal is to provide integrated licensing systems for activities requiring environmental authorisation in terms of NEMA and other sectoral statutes. This will require an adjustment to the National Environmental Authorisation System (NEAS) so that it can accommodate the licensing requirements of activities that may require authorisation by other organs of state.

3.5 Industry Waste Management Plans

The industry waste management plan (IndWMP) is a planning instrument that will identify how a specific waste stream will be managed by industry. The IndWMP gives industry the opportunity to set out the additional standards that it will meet for waste management activities and how it will adhere to these. The IndWMP will commit the industry to targets for the management of the waste which may include recycling, recovery or re-use targets or in some cases waste collection targets depending on the waste stream. The industry will be required to report on these agreed targets, which will indicate the success or not of the plan.

IndWMPs can be waste stream specific or company specific, and can be submitted on a voluntary basis or as directed by the Minister through a notice in a government gazette. IndWMPs will assist industries to:

Set performance targets for the management, recycling, re-use and recovery of either a specific waste stream or wastes from a specific industry.

Support a licence application.

Identify the regulatory support required to achieve maximum compliance with the plan among industry stakeholders.

3.5.1 Mandatory and Voluntary IndWMPs

The Waste Act provides for mandatory and voluntary industry waste management plans. The Minister or MEC may give directions that a person, category of persons or an industry that generates waste prepares an IndWMP. The Minister is the regulatory authority for IndWMPs in which waste generating activities affect more than one province or are conducted in more than one province.

The following industries are preparing mandatory IndWMPs in consultation with DEA:

Tyre industry for waste tyres.

Paper and Packaging for packaging and paper waste.

Lighting industry for mercury containing lamps e.g. CFLs.

Pesticide Industry for residual pesticides and pesticide containers.

Over the course of the next five years, IndWMPs will be required for different forms of ewaste and batteries, and other waste streams that are best managed through an IndWMP.

3.5.2 Plans for waste streams or individual companies

IndWMPs apply to a waste stream or an individual company.

A waste stream IndWMP applies to producers of products that result in a particular type of waste. Producers include importers of a product or product type. Examples of waste streams that would be considered for this type of plan include various types of batteries, waste tyres, residue pesticides and pesticide containers, paper and packaging, and various types of waste electric and electronic equipment (WEEE).

Individual company plans would apply to large companies that have multiple waste management activities that require licensing and / or comprise of multiple sites that have multiple licensing requirements. A company IndWMP can support multiple permit applications where waste management activities have been listed and must be licenced. The plans could also support a motivation to the Minister for listed waste management activities not to require a licence.

3.5.3 Content of IndWMPs

Section 30 of the Waste Act specifies the minimum requirements for a mandatory plan, but the Minister or MEC may include additional requirements. Elective plans should also provide at least the information stipulated in Section 30. DEA's Generic Guideline Document for Preparing Industry Waste Management Plans elaborates on the requirements for the different types of plan. The guideline emphasises that an IndWMP should support decisionmaking by generators of waste. The guideline reinforces the need for accurate information, including a detailed status quo analysis of the current waste management system, realistic targets for waste minimisation, milestone indicators with achievable time-frames for different interventions and sound record-keeping systems. The IndWMP must remain current through regular reviews and updates.

3.5.4 Preparation of plans

IndWMPs must be produced in a consultative manner in line with the directions given by the Minister or MEC, and the contents of a proposed IndWMP must be brought to the attention of relevant organs of state, interested persons and the public. Any comments submitted in respect of the IndWMP must be considered, and a copy of all comments received must be submitted with the proposed plan to the Minister or MEC.

On occasion the Minister or MEC may give directions that an independent person prepares an IndWMP for the cost of the persons or industry responsible for the waste-generating activities. The Minister or MEC will only invoke this measure if no representative body or structure is capable of preparing an IndWMP, or if the fragmented nature of an industry precludes the industry from agreeing on a suitable person to prepare the plan, or if the responsible party doesn't satisfactorily comply with an initial request.

The Minister may require that an organ of state, excluding a municipality, prepares an IndWMP, and similarly, the MEC may request that the provincial department responsible for environmental affairs prepare an IndWMP. Organs of state may be required to prepare an IndWMP where the industry is largely dominated by state owned entities, or the industry relates to defence of the state or deals with information that is deemed sensitive to the security of the state. The industry responsible for producing the waste must pay the cost of preparing the plan.

3.5.5 Approval of plans

On receipt of the plan the Minister or MEC may approve the plan with amendments, or require a revised plan or reject the plan with reasons48.

An approval must appear in the gazette and stipulate the period for which the approval applies. An approved plan prepared by an organ of state or provincial department must indicate in the gazette how and when the plan will be implemented.

If the Minister or MEC requests amendments and the person(s) preparing the plan do not meet these within the stipulated timeframes, it constitutes a failure to submit an IndWMP. The Minister or MEC will reconsider a plan if it is the first resubmission.

If the Minister or MEC rejects an IndWMP more than once, or if a person required to produce a plan fails to do so, then the Minister or MEC may specify the waste management measures that must be taken49, ensuring that the industry is not advantaged by the failure to submit an approved plan.

IndWMPs must be reviewed at intervals specified in the written approval or the gazette. IndWMP review periods will take into account the review periods of waste management licences.

As per section 32 of the Waste Act.

As per section 33(1) of the Act.

3.6 Extended Producer Responsibility

IndWMPs can include voluntary producer responsibility schemes for particular waste streams whereby producers, importers or retailers take responsibility for the waste generated by their products beyond point-of-sale and choose the most effective way of meeting their responsibilities.

The Waste Act also provides for the declaration of mandatory Extended Producer Responsibility (EPR) schemes whereby the Minister prescribes how a waste stream should be managed and the required funding mechanism to do so. Mandatory EPR schemes can be declared when voluntary schemes provided for by IndWMPs have failed to effectively manage a waste stream.

It is the Minister's prerogative to declare the application of EPR to a product, group of products or waste stream. The declaration must be done in consultation with the Minister of Trade and Industry by notice in the government gazette. The Minister must also consult the Minister of Finance regarding any financial arrangements for an EPR programme. This is especially pertinent where the EPR programme is likely to require changes to product design, or impact significantly on the economy or economic sectors.

The characteristics of a product determine if an EPR programme is appropriate for it. Products with the following characteristics are candidates:

Products with toxic constituents that may become a problem at the end of life. Examples include: batteries, electronics, used oil, pharmaceuticals, paint and paint products (latex oil-based paints and thinners), pesticides, radioactive materials, products containing mercury and cadmium including thermometers, thermostats, electrical switches (including automotive), and fluorescent lamps.

Large products that are not easily and conveniently thrown out as waste. Examples include: carpets, building materials, TVs, computers, appliances, tyres, propane tanks and gas canisters.

Products with multiple material types that make them difficult to recover in traditional recycling systems. Examples include: packaging, electronics, and vehicles.

A risk-based evaluation will establish if a product, group of products or waste stream is suitable for EPR and its consequences. This may include an assessment of legal and administrative difficulties, such as the potential impact on waste avoidance, economic implications (including job creation), potential for contravention of competition requirements, enforcement and the potential for illegal activities. The risk-based evaluation will draw on scientific information and take into account the country's obligations with respect to any applicable international agreements.

The design of the EPR measures for mandatory schemes will include appropriate funding mechanisms to attract consumer participation, the establishment of cost-effective collection and return networks for discarded products, the identification of markets and uses for returned products and materials, and achieving co-operation where multiple firms are involved. This will be done in consultation with the affected producers of the product, group of products or waste stream under consideration.

DEA will develop a set of guidelines in consultation with industry to assist with the development of voluntary and mandatory EPR programmes.

It is important to note that the state is not obliged to fund EPR initiatives, and that the primary obligation for funding rests with producers, retailers and consumers along the value chain. Financial arrangements will need to be tailored to individual EPR programmes, and the key challenge will be to establish who along the value chain bears what portion of the costs. DEA will develop a guideline on the distribution of costs for EPR programmes in consultation with industry.

Figure 3: Process for declaring an EPR programme

3.7 Priority wastes

The declaration of a priority waste is a regulatory measure in terms of the Waste Act that applies to wastes that pose a serious threat to health and the environment. The consequent waste management measures can severely limit or prohibit the generation of the waste. Such a declaration may also require detailed registration and reporting on the waste, limit its import and export, and ultimately culminate in a waste being phased out completely. The criteria for declaring a priority waste will therefore be considered very carefully prior to declaration.

3.7.1 Application

A waste may be declared a priority waste by the Minister, or the Minister on behalf of the MEC, by notice in the Gazette50. The Minister must have reasonable grounds to believe that the waste poses a threat to health, well-being or the environment because of the quantity or composition of the waste. It must also be demonstrated that:

specific waste management measures are required to address the threat, or

that specific waste management measures may improve the reduction, re-use, recycling and recovery rates or reduce the health and environmental impacts of the waste.

Section 14(1) of the Waste Act.

3.7.2 Process for declaring a priority waste

The Waste Act requires the Minister to consult with stakeholders that may be affected by the declaration. A steering committee consisting of affected departments, industries and civil society organisations will guide the process of declaring a priority waste.

Informed decision making will be supported by scientific research, analysis of applicable waste management measures and regulatory and economic impact analyses.

If the declaration of the priority waste will have a significant impact on the national economy, the Minister must consult with the Minister of Trade and Industry and the Minister of Finance before making the declaration.

The following diagram illustrates the process for identifying and declaring a priority waste:

Figure 4: Decision Making Process for Declaring Priority Wastes

Once the declaration of the priority waste and its waste management measures has been decided, the administrative and regulatory mechanisms needed to implement the declaration (including requirements for registering, monitoring, and reporting) will be set out in a plan.

The plan will include the specific consequences of the declaration. Possible consequences may be the prohibition on the import, export, processing, manufacture, or sale of priority wastes (or products likely to generate priority wastes), unless such activities comply with the regulatory measures and requirements in the implementation plan.

3.8 Economic instruments

The Waste Act51 provides for economic instruments, and empowers the Minister, in concurrence with the Minister of Finance, to make regulations for incentives and disincentives to encourage a change in behaviour towards waste generation and management. Economic instruments can change behaviour indirectly by creating a set of incentives and disincentives through pricing. Pricing can offer a more cost-effective and dynamic form of regulation than the traditional command and control approach.

Economic instruments will be applied within the overall fiscal and taxation policy of government.

The selection and use of economic measures, including pricing, taxation, subsidies, incentives and fiscal measures will also be aligned with the principles established by NEMA, including the 'polluter pays' principle. According to the 'polluter pays' principle, all generators of waste (including businesses and households) are responsible for the costs of managing the waste generated. These include not only the direct financial costs of collection, treatment and disposal of waste, but also externalities such as health and environmental impacts.

Before economic instruments can be more widely applied, the pervasive under-pricing of waste services needs to be addressed. The under-pricing of waste services creates the wrong set of incentives, undermines waste minimisation efforts, and ultimately undermines the polluter pays principle. Additional economic instruments will create distortions and be ineffective in this context. DEA and National Treasury will conduct an annual review of pricing, and review the effectiveness of measures to correct pricing of waste services. This will be the focus of activities for the next three years.

During this period additional economic measures will be investigated, and evaluated in terms of their effectiveness, and potential impacts on income distribution and competitiveness. Consultation with industry and stakeholders will take place prior to the application of marketbased instruments.

DEA and National Treasury will undertake further research into implementing or extending the following instruments once under-pricing has been corrected:

Deposit Refund Schemes: These schemes are most suitable for products that are easy to identify and handle; feasible to re-use or recycle; require careful disposal; and where co-operation is feasible between producers, retailers and consumers. Currently the private sector implements such a scheme for a specified range of glass bottles, where the consumer pays a deposit per bottle and the consumer receives a refund per bottle upon return to a retailer.

Waste Disposal Taxes: These taxes address the external social and environmental costs of waste disposal and provide pricing that influences waste generation and disposal decisions by private actors. Waste disposal taxes require that effective regulation and monitoring of landfill sites are in place.

Product Taxes: Product taxes will be directed at products or materials that a policy intends to reduce or remove from production. An example of this instrument is the Plastic Bag Levy52 that consumers who choose to buy plastic bags pay directly.

ax interventions for hazardous waste disposal: Tax interventions for hazardous waste disposal will be considered in instances where more effective management of hazardous waste generators is required.

Tax rebates and benefits: Industries could receive a tax benefit if they promote or implement recycling infrastructure.

As per the National Budget 2010/11 the following waste related environmental taxes and charges are being investigated:

A wastewater discharge levy in terms of the Water Act.

Levies on the waste streams of various products.

A landfill tax at municipal level.

Further research is required into fiscal instruments for integrated waste management as follows:

National Remediation Fund: DEA together with National Treasury will examine a remediation fund for contaminated land as discussed under Section 2.6 Goal 7.

Solid Waste Project Development and Finance: DEA and National Treasury will investigate ways to ensure that capital expenditure in the sector increases; create a robust pipeline of municipal projects; and develop an appropriate capital financing mix. Support for capital financing of waste projects is needed from the private banking sector and Development Financial Institutions, and National Treasury and DEA will examine ways to improve the bankability of municipality's waste management projects.

DEA will work closely with National Treasury to monitor the implementation of the above economic mechanisms and to implement the necessary policy and regulatory tools.

Section 69(1)(bb).

The Plastic Bag Levy is a tax which charges R0.04 per plastic bag in the 2010/11 budget.